Unsubstantiated and uncorroborated seized material alone cannot be considered conclusive evidence for...

Unsubstantiated and uncorroborated seized material alone cannot be considered conclusive evidence for additions u/s 69B. The words "may be presumed" in Section 132(4) provide an option to the Assessing Officer to presume, but it is rebuttable, and the assessee has the right to rebut. Additions cannot be made based on suspicion, conjectures, and surmises. The Assessing Officer must act judicially, fairly, and reasonably, and assessments u/s 153C should be supported by adequate material. Loose sheets, scribblings, and jottings without signatures or authorization from the assessee are unsubstantiated documents and cannot sustain additions. Non-speaking documents without corroborative material and evidence of undisclosed assets or income should..... .....

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